Corrective and Preventative Action (CAPA)

Our company just went into an environmental "Surveillance Audit" for R2. Some advice for people who are getting certified, or thinking about getting certified...

The temptation is to think that on the second audit, you've done this before. You got the initial certification, you think that's the hard part. No. Joining the Army is the easy part. Staying in the Army is the hard part.

When you think about it, there aren't too many economic incentives to keep someone out of a certification, whether it's E-Stewards, or R2, or ISO, etc. What the company is signing up for is a process. It's like joining a church, it's not about your past sins, it's about your commitment to being better.

What happened prior to our Surveillance Audit was that I took two trips to the Southwest (things are heating up at Retroworks de Mexico, despite the snow down there) and left people I trust in charge. They have earned my confidence, as in confidence to do what I've trained everyone is our culture to do.

In that vein, everybody at the plant was motivated, without me telling them so, to make the place ship-shape. We were proud of our company, and open to the audit with open arms. A special clean up crew was assigned room by room to make sure everything was swept up and ship shape.

Well, we do "batch work" a few times a year. Like we let the projection tubes build up until there will be enough of them to actually fill barrels with ethyl glycol. If you do them as they come in, a few per day, you tie up more floor space with 1/8 full barrels which are actually more susceptible to spills than the projection tubes they were stored in. So it makes sense, operationally, to store up 30 gaylords of the projection tubes when things are busy in the summer, and to keep people employed in the winter by draining them in a batch.

LCDs are similar. In the first batch, you test working. In the second batch, of the ones not working, you examine for capacitors and other "easily" repairable problems (for those in the know). In the third batch, you leave for last the de-manufacturing of the busted-up-beyond-hope LCDs that need demanufacturing.

You are proud of the quality of your reuse. We are led to believe, and it's true, that a lot of companies will sell the LCDs "as is" in a mixed lot. Economically, you can "externalize" the cost of the LCD demanufacturing if you use the reuse value of the working and repairable to make the other LCDs tag along, as "toxics along for the ride". So we haven't been doing that, we are proud to be tackling the hardest part of the work during the R2 winter surveillance audit.

So you've got a couple of people doing something new, something they aren't as experienced in, in the "batch work". And you have a crew of eager clean up guys, circling around, trying to make the place look neat and orderly before the auditor arrives.

Crack.

That was the thin ice.

Efficiency, Good Work, Value, Accountability. Get 'Er Done, combined with Know How... Just enough structure to get you halfway across the icy Vermont lake.

When you manage a business this way, you wind up with young people trying to create an appearance of tidiness, and along the way, something can happen. Something can get moved, poured, spilled, crushed, forklifted-sideways. You have two people doing something - batch-worker and cleaner-upper - empowered by the deadline to make sense of material they may not be trained to manage.

The tiny fluorescent lamps that come out of an LCD... when they are taken out carefully, some can actually be reused (though many working ones have no demand). But when mop-crew-dudes come to move stuff with new-to-task-batch-work-dudes, you have a recipe for an INCIDENT.

The timing of the incident may have been triggered by the Audit itself. That may make you want to excuse it in your mind. Had you not been trying to get the place ready for the auditor, you would have managed that pile of X when you were strolling through the plant and noticed it. "Hey, take these lamp ballasts off that table. Here, didn't someone tell you how to package these so they can actually be MOVED later? If you put them like that it makes your job easier, but when you need to move them they are likely to get broken. You were going to move them into a WHAT?? No, no, no... you can't do that because...."

No, this time you weren't there to supervise. You were confident. Confident in your Efficient, Good Work, Valuable, Accountable, Get-er-Done Know-How operators.

The real value of an ISO certification, or other certification, in my opinion, is this.

When you have, for example, a CAPA program - Corrective And Preventative Action - there is a cost to a mistake. It shuts everyone down for awhile. The staff have to do paperwork.

The paperwork isn't efficient.

What is efficient is the time the next Clean Up or Batch Work crew will take to ask before they use Git Er Done force on a fragile or unstable object.

When they take the time to ASK, because they know something happens when they aren't trained and do something wrong, guess what? You no longer need to be walking around the plant noticing. You can be in your office, and if something bad could happen, you can be confident that someone will ask you about it.

That makes CAPA sound a little bit like a punishment, and in a way yes, the process is inefficient enough to be a deterrent. But it also makes you train people first. Letting them learn on the job is pretty easy.

Fishing your colleagues off the bottom of a freezing river, not so easy.

Facing your worker who brought mercury home on his unwashed hands, picked up a teething ring, and placed it in the wet mouth of his 5 month old daughter, that shouldn't be easy either.

I've been told by a lot of people that this is painful, but the best thing they ever done. CAPA and ISO start to sound a little bit like an AA meeting at times, with people writing stories about how it saved them money. It may or may not save you money, and I'm still cautious of creating jobs which are better paid TALKING about recycling than the people picking up the copper, steel, plastic, aluminum, and DOING the recycling.

Ok admittedly, I haven't gone all European on you, dear reader. You don't really want the auditor, or our own certification managers, to be so proud of our certification that they think they are better than the folks on the floor pushing and getting er done. But you don't want to be such a macho know-it-all cock-sure manager that you think acronyms are for woosies, and don't train your people well enough.

This is an opportunity to be ashamed. Genuinely, constructively, less self confident. More driven by concern for your workers and their families, less so by the win-win culture of the recycling business.

It can be pretty annoying. The ISO and R2 systems audits have to find SOMETHING, somewhere, to test your system, to test your fire alarm. They know that stuff happens when they aren't there, and they probably know that some stuff happens because people got nervous and hurried with something just before they got there... Once they find something, important or not, you have to show you know how to do CAPA. Corrective And Preventative Action. If you don't know what CAPA stands for, you need to.

If they say you haven't had a 6-month OSHA certification of a ladder they saw in the building, it's like pushing the test button on a smoke detector. Do you have a system or culture that can respond to a mistake, and start a process which is just onerous enough to create communication, show responses, correct and prevent, and analyze the root causes of the mistake? Did checking the ladder make you check for something else... like training the guy removing glycol?

An audit is just two days. And if the auditor is there on a good day when you DIDN'T just add a Git-er-done Mop Crew to a New Batch work Dude area, they need to test your mettle. And they need to see how much of your response is excuses, denial, ignorance, and just-too-busy-to-deal-with-it-ness.

We have learned enough from our first year of R2 Certification to go for the ISO. And I hope it won't create too much of a talking-about culture at our recycling plant. But knowing the risks of inefficiency, vs. the risk of fishing my colleagues from a river or looking at an inadvertently poisoned child, I know that the water has to get just a little bit colder for this Ice Skating we gotta get done in Middlebury.

And in Mexico.

We are mortal, our staff are mortal, no one is perfect. We can believe in ourselves. But we can believe in ourselves a little bit more if we really expose ourselves to the cold reality of external audits.

There are things about the R2 standard I really don't like (if we had a giant shredding machine in the middle of the plant, I don't think "mop up crews" would leave much evidence of how things were handled... R2 gives an advantage to planned obsolescence companies). But I do believe now that Good Point Recycling will be a better company a year from now than we were a week ago.